Steven Charles Hunt President, ShipMate, Inc. from here to there: topics in transportation If you’re planning on a Special Permit … plan early! Many years ago, I worked at U.S. Coast Guard 30 Spray April 2013 Headquarters in Washington, D.C. I was part of a small group that was responsible, in part, for reviewing special permit applications for those applicants that wanted to offer dangerous goods all or in part by vessel, but whom could not comply with the regulatory requirements for one reason or another. Actually, back then, they were referred to as Dept. of Transportation (DOT) Exemptions. We processed approximately six applications a week, and provided our comments and recommendations to the Research & Special Programs Administration (RSPA), now known as the Pipeline & Hazardous Materials Safety Administration (PHMSA). Our charge was fairly straightforward—would the applicant’s proposal provide an equivalency of safety or not? If so, we offered our recommendation for approval. If not, we recommended that the application be denied and returned to the applicant to be reworked. It might have taken us a few hours to review each application and the applicant would receive an approval or denial from RSPA generally within thirty days or less. Delays in Processing Over the course of 20 years, I may have authored three hundred or more applications for permit or approval, but it seems that within the past three to four years, the application process has become increasingly more difficult and much lengthier. What would have been expected in 60 days is now taking six months or more. In fact, I just received an approval for a client who had submitted a request for special permit more than 18 month ago! Therefore, if you are planning on obtaining a special permit or Competent Authority Approval, you are cautioned to begin the planning process early. Do not wait until the last minute to file an application and then request emergency (expedited) processing because you failed to plan properly.
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